Updated Thursday June 17, 2021 - The Department of Education released the Federal Register notice with the effective date of the notice June 17, 2021 and Implementation date of August 16, 2021. Indicated in the Federal Register Notice is the following:
" Institutions may implement the changes as early as the date the Federal Register notice publishes. They must implement the changes no later than 60 days after the date of the Federal Register notice (implementation date). To make Title IV aid accessible to as many students as soon as possible, the Department of Education (Department) will implement these changes in three phases across three award years: The 2021-2022, 2022-2023, and 2023-2024 award years. "
CampusLogic has reviewed the Federal Register Notice provided on June 17, 2021 and the Dear Colleague Letter provided on June 11, 2021 and has determined the following changes will be made to StudentForms on June 24, 2021.
If you do not want CampusLogic to remove the Selective Service or Drug-Related Conviction tasks from a student's account (#3 above), where no action was taken (submitted documentation), please contact your Customer Success Manager prior to June 24, 2021.
A DCL was released on June 11, 2021 providing details on the early implementation of the removal of the Selective Service and Drug Conviction requirements for Title IV eligibility due to the FAFSA Simplification Act. The full DCL may be read here.
Please note: At this time, information on whether the same early implementation of the Selective Service requirements will apply to California DREAM ISIRs has not been provided by the California Student Aid Commission. This known issue will be updated as information is available. It would be appreciated if our school partners would share through support any additional information or guidance they receive. As a reminder on May 19, 2020 an executive order from the Governor of California waived verification of the Selective Service requirement for 2019-2020 and 2020-2021 but was not extended to the 2021-2022 award year. Typically, they follow the same updates as the Federal ISIRs.
Below is a summary of our interpretation of DCL GEN-21-04
These changes may be implemented by the Department of Education by providing a 60 day notice in the Federal Register. Once the Federal Register has been published we will provide an update to this known issue with the implementation date. Once the date has been published in the Federal Register, a school must implement the changes no later than 60 days after the date of the notice.
For 2021-2022 and 2022-2023 the Selective Service and Drug Conviction questions will remain on the FAFSA.
For 2021-2022 comment codes 030, 033, 057, 053, 054, 056, 058 will continue to appear on the ISIR indicating resolution is required. For ISIRs received on or after the implementation date, these c codes must be ignored and the school would proceed to award and disburse aid to students if otherwise eligible. A school is not required to go back and reprocess, package, or award aid for ISIRs received prior to the implementation date unless requested by the student, but it is recommended. Federal Student Aid will be notifying students who were determined ineligible to either the Selective Service or Drug Conviction question for ISIRs received prior to the implementation date, to contact their school's financial aid office.
For 2022-2023 comment codes 030, 033, 057, 053, 054, 056, 058 will continue to appear on the ISIR however the comment text will be updated to indicate that no further action is required. Institutions must ignore these comment codes and may not use the comment codes as a reason to deny Title IV aid to an otherwise eligible student.
For 2023-2024 and beyond, the Department is planning to remove both questions and the option to register for Selective Service from the FAFSA. It also plans to remove the c codes and messaging indicating resolution is required for Title IV aid eligibility.
Once the Federal Register notice has been released CampusLogic will review it and determine implementation details that will be shared through both this known issue and your Customer Success Manager.
This communication is not meant as regulatory guidance or advice to a school. It is the responsibility of the institution to ensure that the implementation, configuration, updates to, and utilization of the tool set purchased from CampusLogic are meeting Federal and State regulatory requirements/sub regulatory guidance, institutional polices, and accrediting body standards and requirements.
Update June 23, 2021 - As an update to our previous notice of StudentForms updates to support new Federal Guidance for Selective Service registration and Prior Drug Conviction, we have received feedback from many institutions that due to SIS readiness and state grant eligibility requirements institutions are not ready to change the current functionality. Based on this feedback, we are postponing the changes and the removal of open items previously communicated for this Thursday, June 24th.
Institution's wishing to act immediately, may use the waive functionality in StudentForms to remove these requirements until the August 16th deadline provided by in the Federal Register. We will provide additional guidance for StudentForms changes by July 22nd to help you prepare for the August 16th changes and options for managing State requirements at that time.
Update July 20th, 2021
Selective service and drug conviction adjustments: (As a reminder, the Federal implementation guidance for this item has a deadline of August 16, 2021.)
Schools that wish to continue collecting selective service and drug conviction documentation do not need to take any action. Many state authorities are still requiring institutions to collect selective service and drug conviction documentation from grant recipients. For this reason, the standard configuration for StudentForms will continue to request these documents.
Schools that wish to no longer collect documentation for selective service and drug conviction will need to notify their customer success manager via a support ticket that they would like the requirements removed. This will be done through a custom trigger or rule.